The CCE and Section 602.13
As has been (not so) widely reported, the National Advisory Committee on Institutional Quality and Integrity (NACIQI) of the US Department of Education met on December 14, 2011 to consider the Council on Chiropractic Education’s petition for renewal of recognition. The process of continuing the recognition of an existing agency is generally unremarkable, often requiring only 15 minutes or so of discussion.
This proceeding involving CCE was anything but routine, with four hours of public comments, agency responses, and deliberations. In the end the Department of Education staff identified over 40 compliance issues that the CCE needs to address within the next year. These areas of deficiency exceeded the norm for re-accreditation violations. Chairman Wickes referred to the quantity of citations as “an embarrassing number.” The CCE expects an official letter from NACIQI approximately 90 days from the hearing date and they expect to be granted a maximum of 12 months from the date of this document to address the identified deficiencies. The Council predicts a deadline of March 2013 to complete a compliance report to NACIQI’s committee liaison.
Following overwhelming written and oral testimony to the committee expressing concerns about the CCE from the profession at large, the NACIQI added the following statement: “In addition to the numerous issues identified in the staff report, NACIQI asks the agency to demonstrate compliance with Section 602.13 dealing with the wide acceptance of its standards, policies, procedures, and decisions; and to address how its standards advance quality in chiropractic education.”
The “wide acceptance” issue is, of course, scope and definition of chiropractic practice and whether or not to marginalize the subluxation model.
The CCE’s own Accreditation Standards as of January 2012 define chiropractic primary health care as, “care that is provided by a health care professional in the patient’s first contact within a health care system that includes an examination and evaluation, diagnosis and health management. A Doctor of Chiropractic practicing primary health care is competent and qualified to provide independent, quality, patient-focused care to individuals of all ages and genders by: 1) providing direct access, portal of entry care that does not require a referral from another source; 2) establishing a partnership relationship with continuity of care for each individual patient; 3) evaluating a patient and independently establishing a diagnosis or diagnoses; and 4) managing the patient’s health care and integrating health care services including treatment, recommendations for self-care, referral, and/or co-management.”
The IFCA website claims that “the CCE’s definition of chiropractic is clearly in violation of 602.13 as it is not widely accepted. A review of chiropractic state practice acts as listed by the Federation of Chiropractic Licensing Boards, which has been previously provided to this committee, revealed that the majority of states (41 to be exact) do not allow for chiropractors to serve the public in the broadly defined role of primary care physician. The remaining states that DO ALLOW for a broader scope of practice do not define chiropractors as being the coordinators in the public’s use of the health care system in the way the CCE standards do.”
They argue that this will make it increasingly more difficult for chiropractors to earn a living.
Naturally, there are two sides to the argument. Some groups, like the West Hartford Group, Inc. represent what might be called the progressive side of the argument and would like to leave subluxation behind. The conservative side is represented by a coalition which includes the Foundation for Vertebral Subluxation (FVS), the International Federation of Chiropractors and Organizations (IFCO) and the Movement for Chiropractic Quality & Integrity (MCQI). This coalition argues that the CCE misrepresents the bulk of the chiropractic profession when it marginalizes subluxation, that the CCE is attempting to turn chiropractic into medicine, and that this is in violation of Section 602.13. In other words the CCE’s position does not have the support of the majority of the profession.
And so the saga continues.